December 22, 2015
Environmental Protection Agency Docket Center (EPA/DC), (28221T)
1200 Pennsylvania Ave. NW
Washington, DC 20460-0001
Ms. Brittany Pruitt, Pesticide Re-Evaluation Division (7508P)
Office of Pesticide Programs
Environmental Protection Agency
1200 Pennsylvania Ave. NW,
Washington, DC 20460–0001
Re: Docket ID No. EPA–HQ–OPP–2010-0626.
Dear Ms. Pruitt:
In response to the Environmental Protection Agency’s September 25, 2015 Federal Register notice opening a public comment period on EPA’s draft human health and ecological risk assessments for the registration review of a group of 35 different pesticides known as sulfonylureas and other identified chemicals, the National Cotton Council (NCC) appreciates the opportunity to provide the following comments related to the importance of the pesticide tribenuron-methyl as a weed management product.
The NCC is the central organization of the United States cotton industry. Its members include producers, ginners, cottonseed processors and merchandizers, merchants, cooperatives, warehousers and textile manufacturers. A majority of the industry is concentrated in 17 cotton-producing states stretching from Virginia to California. The NCC represents producers who cultivate between 10 and 14 million acres of cotton. Annual cotton production, averaging approximately 16 to 20 million 480-lb bales, is valued at more than $5 billion at the farm gate. The downstream manufacturers of cotton apparel and home furnishings are located in virtually every state. Farms and businesses directly involved in the production, distribution and processing of cotton employ more than 230,000 workers and produce direct business revenue of more than $27 billion. Accounting for the ripple effect of cotton through the broader economy, direct and indirect employment surpasses 420,000 workers with economic activity well in excess of $120 billion. In addition to the cotton fiber, cottonseed products are used for livestock feed, and cottonseed oil is used as an ingredient in food products as well as being a premium cooking oil.
Tribenuron-methyl is labeled for use in cotton production as a burndown herbicide (removing weeds prior to the planting the crop) to control winter annual broadleaf weeds such as henbit, chickweed, small wild radish, and curly dock. It is often used in combination with thifensulfuron. The product is applied during late fall or winter in order to mimimize weed populations requiring clean-up prior to spring planting. Both tribenuron and thifensulfuron are sulfonylurea herbicides whose mode of action (MOA) is generally referred to as Acetolactate Synthase (ALS) inhibitors. Although some plant species are known to be resistant to ALS chemistry, the chemistry continues to play a vital role in resistance management strategies that do not solely rely on one MOA, but rotate or combine MOAs in order to effectively control the multitude of weed species present and minimize further resistance evolution of weed populations. While use of tribenuron may not appear large, the importance of retaining multiple MOAs and products that fit niche uses in weed management is very important for sustainable cotton production. The NCC urges EPA to retain the resistance management benefits of multiple MOAs and to retain this label as a viable option as cotton producers identify herbicide products that fit the necessary weed management needs of their farms.
VP – Washington Operations